Method for creating and delivering customized compliance information

ABSTRACT

A method and system to create personalized investor information packages, based on investor information, to be delivered to the investor to satisfy both compliance regulations and investor preferences. The method and system may deliver information in a paper or electronic format.

CROSS-REFERENCE TO RELATED APPLICATIONS

This application is a continuation of U.S. patent application Ser. No.13/169,692, filed Jun. 27, 2011, which is a continuation of U.S. patentapplication Ser. No. 12/875,002, filed Sep. 2, 2010, which is acontinuation of U.S. patent application Ser. No. 10/877,904, filed Jun.25, 2004, which claims priority to U.S. Provisional Application Ser. No.60/482,317, filed on Jun. 25, 2003, the entirety of which are herebyincorporated by reference.

TECHNICAL FIELD

This invention relates to providing securities information to investors.

BACKGROUND INFORMATION

Increasing numbers of individuals every day are conducting theirpersonal financial business, such as bathing and investing, on-line.Today, with access to the Internet so prevalent, many are activelymanaging their own stock portfolios on a day-to-day basis. Theefficiencies gained by using the services of on-line brokerages such asE*Trade, Datek, and Ameritrade, have made the associated per-trade costssufficiently low to make such transactions economically feasible for anindividual.

While the Internet has allowed increased access to the trading ofstocks, effectively lowering the barrier of entry for an individual,on-line brokerages must still comply with reporting rules from theUnited States Securities and Exchange Commission (SEC). With respect tothe purchase of certain securities such as mutual funds, a user must beprovided with certain documents, such as a fund prospectus prior to thepurchase of any shares in the mutual fund. In addition, after purchasingshares in a mutual fund, subsequent reports also must be sent to theinvestor.

Compliance information, as used herein, is information which must beprovided to individuals to comply with the regulations of a governingbody or non-governmental regulating body. Securities information is ageneral term which relates to any information dealing with securitiesand/or securities related transactions. Correspondence relating tosecurities, filing information, holding information, prospectusinformation are all examples of securities information. Certain types ofinformation may be both compliance information and securitiesinformation, such as when securities information is information about asecurity that a government or a stock exchange requires be madeavailable or delivered to an investor (or potential inventor) in thatsecurity. For example, the SEC and the National Association ofSecurities Dealers (“NASD”) each requires the filing of certaininformation by an issuer of securities; this is an example of securitiesinformation that is also compliance information. The SEC and NASDrequire that a certain subset of the securities information be madeavailable to an investor in a security—this is also complianceinformation, and is also referred to as regulated financial informationdocuments (“RFID”).

One example of compliance information is a mutual fund prospectus. Themutual fund prospectus could be located somewhere within a filing thatalso contains other securities information, such as an amendment to adifferent prospectus, or a semi-annual report. Compliance informationfor a mutual fund may include, but is not limited to, prospectuses,supplements to prospectuses (“stickers”), statements of additionalinformation (“SAI”), supplements to SAIs, annual reports, andsemi-annual reports. Certain sales and marketing information can also beconsidered compliance information since its distribution is alsoregulated by government agency and stock exchange rules. As anotherexample, compliance information for a variable annuity fund includes thecompliance information for the variable annuity fund, and the complianceinformation for each of the funds available for investment.

Recently, government agencies and securities exchanges have begunallowing securities issuers and intermediaries to comply withinformation delivery requirements by approving the delivery of theinformation in an electronic format, for example, by transmitting theinformation from one computer to another over a computer network. TheSEC currently requires that investors consent to receiving complianceinformation in an electronic format. One method for obtaining such userconsent is described in U.S. patent application Ser. No. 09/023,039filed on Feb. 12, 1998 and herein incorporated by reference. Electronicdelivery of compliance information has significantly reduced costs forentities which are required to disclose securities information.

Securities information is available in various electronic databasesincluding the Securities SEC's EDGAR database. EDGAR, the ElectronicData Gathering, Analysis, and Retrieval system, performs automatedcollection, validation, indexing, acceptance, and forwarding ofsubmissions by companies and others that are required by law to fileinformation with the SEC. The primary purpose of EDGAR is to increasethe efficiency and fairness of the securities market for the benefit ofinvestors, corporations, and the economy by accelerating the receipt,acceptance, dissemination, and analysis of time-sensitive corporateinformation filed with the agency. EDGAR information is available on theInternet at www.sec.gov. Other bodies such as the United States InternalRevenue Service (“IRS”) may also offer similar storage of informationwhich may be relevant to the exchange of securities.

Although securities information is available from databases like EDGAR,the information is not readily available in a useful electronic formatthat enables compliance with government and securities exchangeregulations, especially with regard to mutual funds and othernon-corporate securities. EDGAR, as a result of its design, makesinformation regarding non-corporate securities difficult to find. InEDGAR, mutual fund information, for example, is listed as a submissionof the corporate issuer, not the fund name that is marketed to theconsumer, and one submission may include information for more than onemutual fund. EDGAR submissions also may include updates and amendmentsto earlier submitted information. It is quite possible for a singlemutual fund to have more than fifty amendments to its complianceinformation. An investor attempting to locate the complete set ofcompliance information for a mutual fund directly from EDGAR would needto retrieve all applicable amendments. This is time-consuming, and it isdifficult for the investor, when attempting to gather complianceinformation from EDGAR, to know if all the amendments have actually beenlocated, if the retrieved information about the fund is complete, or ifthe retrieved information is up-to-date.

Before securities information is distributed to investors it may beupdated and “cleaned” so that the information appears in a more usefulformat to the investor. One process for processing raw securities datainto a useable format is described in U.S. Pat. No. 6,122,635, issued onSep. 19, 2000 and herein incorporated by reference.

Despite the availability of delivering compliance information inelectronic form, many entities still rely on more traditional papermethods of delivering compliance information. One obstacle to widespreadelectronic delivery is the variable nature of the industry. Due to heavyregulation by federal and state agencies, financial institutions thatmanufacture and distribute securities information have been at adisadvantage in building new delivery solutions.

As a result, entities rely on the industry practice, which is to sendeach investor the contract prospectus and all sub-account prospectusesin which the investor may allocate funds. This procedure is normallypracticed for both pre-sales materials and on an annual basis after anaccount is opened. According to NAVA's Annuity Fact Book, the averagenumber of sub-accounts available in a retail contract was 33 in 2001.Using average page counts derived from the EDGAR database, this meansthe industry is sending an average of over 3000 pages to an investor peryear. This results in over 30 billion pages produced annually for theindustry.

These pages are typically sent in three mailings occurring in February,May, and August each year. Annual reports for all sub-accounts (onaverage 33) are sent in February. May is the largest mailing andincludes the contract and sub-fund prospectus. In August, semi-annualreports for the sub-funds are sent. Annual and semi-annual mailings mustbegin within 60 days of the closing of the relevant sub-fund accountingperiod. This is for the average of 33 sub-accounts per contract,regardless of the investor's allocation. This system yields billions ofpages of compliance information are printed and shipped to warehouses.Workers then pick documents from shelves and pack them into envelopesfor shipment, or the individual documents are combined into large booksof paper that can be large and heavy. Those documents are expensive tomaintain and to ship, and frequently are wasted as complianceinformation can rapidly change and quickly render pre-printed pamphletsobsolete.

On the investor side, the system can be overwhelming. Individualinvestors receive thousands of pages a year, much of it irrelevant tothe particular investor.

The current system is unsatisfactory to both investors and brokerages.

SUMMARY OF THE INVENTION

What is offered is a system for distributing compliance information to auser, the system comprising: a compliance information manager whichgathers compliance information from one or more sources; a preferencedatabase which stores data regarding delivery instructions for at leastone user; a distribution controller which determines how a user shouldreceive compliance information based on said delivery instructions; anda distribution manager which initiates publication of at least a portionof the compliance information to the user based on a determination madeby the distribution controller.

The publication may comprise sending a physical copy of the portion ofthe compliance information to the user. The distribution controller maybe located on the same machine as the distribution manager. Thepublication may be initiated by the distribution manager is executed bypublishing the portion of the compliance information to the user in anelectronic format. The distribution controller may also determine how auser should receive compliance information further based on compliancerules governing said compliance information

The portion of the compliance information may contained in the body ofan e-mail message and may be sent as an attachment to an e-mail message.The compliance information in electronic format may be located on aninformation storage device sent to the user. The compliance informationin electronic format may be stored on a server which is accessed by theuser; the server may be located on the same machine as the distributionmanager.

The distribution manager may format the portion of the complianceinformation prior to publication. The data regarding deliveryinstructions stored by the preference database may include preferencesof the user and/or those of a brokerage. The compliance information maycomprise securities information. The securities information may compriseat least one mutual fund prospectus. A portion of the complianceinformation gathered by the compliance information manager may beobtained from EDGAR, a brokerage, a publicly traded corporation and/oranother source.

The distribution manager may record the publication of at least aportion of the compliance information to the user. The distributionmanager may report the publication of at least a portion of thecompliance information to the user to a brokerage, and/or a complianceenforcing body; the compliance enforcing body may be the SEC.

The system may further comprises a print manager, wherein: thedistribution manager initiates publication of at least a portion of thecompliance information to the user by sending a request to the printmanger, and wherein the print server causes a physical copy of the atleast a portion of the compliance information which conforms with thedetermination made by the distribution controller to be printed and sentto the user. The print server may print and send physical copies ofportions of compliance information together in a manner which takesadvantage of bulk rates. The distribution manager and the print servermay be located on the same server. The preferences of the user mayinclude one or more of the following types of information: contactinformation, holdings information, display information, or deliverypreferences. The preferences of the user may be obtained from the user,and/or from a brokerage.

The portion of compliance information may be published to the user alongwith non-compliance information; the non-compliance information may bepublished to the user in accordance with the delivery instructions. Thedelivery instructions may include information regarding priorpublications of compliance information to the user.

Publication may be initiated in response to a transaction by the userand/or in response to a new or altered piece of compliance information.The compliance information manager may gather compliance informationdaily. The existence of a need to publish compliance information mayalso determined daily.

A method is also offered for distributing compliance information to auser, the method comprising: obtaining compliance information from oneor more sources; obtaining delivery instructions for at least one user;determining how a user should receive compliance information based onsaid delivery instructions; and initiating publication of at least aportion of the compliance information to the user based on thedetermination. The method may be varied in ways similar to the system asdescribed above.

Also offered is a method for providing securities information to a user,the method comprising: obtaining user information; obtaining securitiesinformation; identifying, based on the user information, a portion ofsecurities information to deliver to a user; customizing, based on theuser information, the portion of securities information; and sending thecustomized portion of securities information to the user. The method maybe varied in ways similar to the system as described above.

The system and methods described above may be used for securitiesinformation instead of compliance information.

Also offered is a method for distributing securities information to auser, the method comprising: obtaining electronic securities informationfrom EDGAR; processing the electronic securities information accordingto securities holdings of a user; providing to the user a portion of theelectronic securities information related to the holdings of the user.The method may be varied in ways similar to the system as describedabove.

Also offered is a method for delivering compliance information to aninvestor, the investor participating in an investment plan, theinvestment plan offering a plurality of securities to the investor, theinvestor owning a first portion of the plurality of securities and notowning a second portion of the plurality of securities, the complianceinformation comprising data which an issuer of a security provides to aninvestor pursuant to SEC requirements, the method including acts of: (A)selecting a body of compliance information which is related only to thefirst portion of the plurality of securities; and (B) delivering thebody of compliance information to the investor. The method may be variedin ways similar to the system as described above.

BRIEF DESCRIPTION OF THE DRAWINGS

In the drawings, like reference characters generally refer to the sameparts throughout the different figures.

FIG. 1 shows a high level overview of the document management anddelivery system according to one embodiment;

FIG. 2 shows how data may be loaded into the system according to oneembodiment;

FIG. 3 shows how documents delivery orders may be formulated by thesystem according to one embodiment;

FIG. 4 shows how documents may be delivered by the system according toone embodiment; and

FIG. 5 shows a general comparison of how document delivery occurs withprior art systems and with one embodiment.

DETAILED DESCRIPTION

A method and system are offered to create and publish personalizedinvestor versions of the large information packages, based on knowledgeof the investor portfolios, compliance business rules, preferenceinformation and the information databases. This blended print andelectronic delivery solution combines the Internet and customizedprinting methods to replace traditional physical warehousing oftraditional offset printed documents. As used herein, the term“publication” or “publish” means to disseminate information. Unlessspecifically noted otherwise, the terms “publication,” “publish,” or thelike do not require a particular medium, such as a physical writtenitem, but rather are media neutral.

Brokerages and information providers prefer disclosing information inelectronic format as it allows for easy and fast distribution tomultiple recipients and users (here the terms “user” and “investor” areused interchangeably) may prefer electronic delivery for its speed andease of handling.

As used herein the terms investor, individual and user are inclusive ofboth the single person who invests and the larger entity (such as smallfirm or investment manager) which may make use of a preference baseddocument delivery system.

Certain users, however, may still prefer receiving complianceinformation in paper form for a variety of reasons including ease ofreading, lack of reliable computer service, etc. Users also may havespecific preferences on how they receive compliance information. Usingtraditional methods of paper delivery which mass produce documents andsend them to investors, there is no way to account for thosepreferences, since no brokerage or company would format complianceinformation differently for each investor due to the prohibitive cost.

The present system offers delivery of compliance information whichincorporates delivery preferences and supports full document managementand distribution. Here, the database understands who gets what, whenthey need to receive it, and how the document should be delivered, i.e.,in a formatted print document or by e-mail. This preference based systemand method insures that investors are not burdened with unnecessarydocuments and receive all required documents. As such, the method andsystem offered easily deliver compliance information which is formattedaccording to individual preferences. The disclosed system and method maybe performed by individuals rather than computer components and thefollowing disclosure should be read accordingly.

In one embodiment of the system, a user provides preference informationwhich can include information relating to how the user prefers to seedocuments (such as font, formatting, print versus electronic, etc.),what documents they receive (such as all compliance information,accounts statements only, general security information only, etc.) andany other preference which may affect how a user wants to receivehis/her information. Those preferences are stored by the system and areused to format specific electronic compliance information into a userpreferred form. Once the preference information is received from theuser, the compliance documents may then be published to the user eitherelectronically, in print, or by any other means according to thosepreferences.

Additionally, other preferences may be taken into account when providingdocument delivery. For example, in the case of delivering securitiesinformation, a brokerage or fund company may have preferred methods ofdelivering information to its customers (for example, to maintain aconsistent image or presentation format). Those brokerage preferencesmay also be taken into account when creating the customized documents tobe published to the user.

FIG. 1 shows an overview of the document creation system according toone embodiment. Although the system described in FIG. 1 may beimplemented with many types of information, for ease of illustrationFIG. 1 shows the document creation system as applied in the area ofsecurities information. FIG. 2 shows how data may be loaded onto thesystem according to one embodiment. Securities data, which may latercomprise portions of compliance information, is sent to EDGAR 100 from acorporation 110. Typically this data is sent from the corporation 110 inplan text or stylized HTML and is filed with the SEC electronically tobe stored in EDGAR 100. This data may satisfy the corporation'sdisclosure requirements. EDGAR's electronic filing processor 102receives the securities data and stores it in the EDGAR database 104.

Each security may be assigned an identification number, such as a CUSIPnumber. Additionally, a security may be identified by an internalidentification number, and/or a stock ticker symbol. The internalidentification number is unique for each security. A CUSIP number is anumber assigned by Standard & Poor's CUSIP (Committee on UniformSecurities Identification Procedures) Service Bureau, the manager of theAmerican Banking Association's CUSIP number system, to identify asecurity. A stock ticker symbol is a symbol assigned by a stock exchangeto identify a security. An investor is likely to reference a security,such as a mutual fund, by any one of: the fund name marketed to theconsumer, the CUSIP number, or the stock ticker symbol, and not by theinvestment company name or the central index key. The system may usethese unique identifiers in obtaining information from EDGAR 100, or ineventually distributing compliance information to the user 1000.

A document management system 200 obtains the securities data from EDGAR100. As EDGAR 100 is constantly updated, the document management systemupdates its data from EDGAR as often as possible, preferably with acontinuous feed. A compliance information manager then gathers thisinformation. In the embodiment shown the compliance information ismanaged by the loading processor 202 and stored on the document database204. Although called the document database 204, the complianceinformation it stores may be stored either as discrete documents (suchas a word file or a .pdf document) or as a collection of data. Thesystem is capable of dealing with either kind of information as incertain cases discrete documents will be preferable and in other cases acollection of data will be preferable. The loading processor 202 obtainsthe securities data from the EDGAR database 104, processes the data, andstores it in the document database 204.

Processing of the EDGAR data is preferable, as the raw form of dataobtained from EDGAR 100 may be difficult for a user 1000 to understand.The processing of the raw data may include cleaning and tagging.Cleaning generally comprises reformatting the raw data into a moreusable document form. Tagging generally comprises marking certainaspects of data so that they may be easily found. Data points which maybe tagged include CUSIP numbers, fund name, revenues, etc. Documenttagging is useful for quickly identifying specific pieces of informationwithin a large securities document which may be relevant to investors,brokerages, or other parties. One method of tagging data may be found inU.S. patent application Ser. No. 10/135,834, filed on Apr. 30, 2002which is herein incorporated by reference. The tagging process analyzesthe securities data and identifies certain components to thehighlighted. Certain business rules may also be applied includingassociating documents with the appropriate CUSIP number so thatdocuments can be matched to specific securities. After the data isprocessed, the system may perform quality assurance to ensure that thesecurities data was acquired, cleaned, and tagged properly.

Once the quality of the processing has been checked the securities datamay be formatted into distinct documents which are associated tospecific securities and may be easily sent to investors or modifiedaccording to user information. Once those documents are formatted thedocument management system 200 may undergo a content check to ensure thedocuments are current with the most recently filed documents. Thedocuments are then stored in the document database 204. The documentmanagement system 200 may also be used with other compliance informationsuch as trade confirms, statements, or similar documents.

The document management system 200 may also obtain securities data fromother sources. Shown in FIG. 2 are two such sources, the corporation 110and the brokerage 500. Other such sources includes news organizations,websites, etc. Securities data obtained from other sources may also bemanipulated by the loading processor 202 in a similar manner as dataobtained from EDGAR 100 prior to storage in the document database 204.

Documents are preferably stored in the document database 204 in a mannerwhich allows easy distribution based on user preferences as describedbelow. If necessary the loading processor 202 will create and formatsummaries, supplements or custom files for certain securities such asmutual funds in order to assist eventual publication to the user.

In addition to obtaining securities information, the document managementsystem also obtains preference information to be stored in thepreference database 206. Preference information may include any type ofinformation which dictates how information is preferably sent. Thispreference may be on the part of a user 1000, brokerage 500 or otherentity.

User preferences may include information about any number of ways a useris to receive his/her compliance information and what complianceinformation he/she is to receive. User preference data may include, butis not limited to, preferences regarding appearance, content, delivery,contingencies, rules based on times (such as day or year), rules basedon types of information, etc. The user may specify specific fonts,formats, text size, languages, or any variety of graphical appearance.When the system is used with securities the preference information mayalso incorporate holding information which indicates which securitiesthe user owns or has an interest in. These may be identified by CUSIP,stock ticker code, fund name, or other identification. This informationmay be regularly updated and recorded to guarantee that the informationsent to the user meets compliant disclosure requirements. For example,if an investor sells out of a particular security early in the year andlater re-purchases the security, the document management system 200 andpreference database 206 may keep track of which information has beensent to the investor so that the investor will not be re-sent anycompliance information he/she has already received. Of course, any newinformation, if applicable, will be sent in order to remain compliant.User preference information may also include a request to be sentcompliance information for a security which the investor has not yetpurchased, but is interested in purchasing. This type of pre-saledisclosure may be useful to the investor and may satisfy certainpre-sale disclosure requirements.

Other user preferences may dictate the order in which documents aresent, the date and/or time they are sent, the location to which they aresent, the individual to whom they are addressed, or other deliveryinformation. User preference information may also incorporate the levelof user consent to receive information electronically. Deliveryinstructions and preference information may contain many particularchoices, but also may simply indicate that a user prefers a defaultpublication, whatever that may be. Delivery instructions and userpreference may be varied and the system is designed to be flexible tothe myriad preferences each user may have.

Preference information may also be obtained from a brokerage 500 orother source. A brokerage 500 may also have preferences as to how orwhen information is presented to its customers. Those preferences may beincorporated by the document management system 200 and used by thefulfillment processor 208. Preferably, the preference information isupdated continuously so that the preference database 206 is kept ascurrent as possible.

Although not indicated directly in FIG. 1 or FIG. 2 , preferenceinformation may be sent to the document management system 200 through avariety of channels. They may be sent electronically in an e-mail orthrough an Internet website. They may be sent directly to the system orthrough an intermediary such as a brokerage. They may also be enteredmanually from a paper submission or obtained over the telephone. Oncethe preferences are obtained they are stored in the preference database206. The preference information may then be used to create deliveryinstructions which dictate how the securities data is to be sent. Ifthere are any conflicts in preference information (for example when userpreferences are contradictory or when preferences which arecontradictory between a user and a brokerage) these conflicts may beresolved by rules applied by the fulfillment processor 208.

The fulfillment processor 208 may function as a distribution controllerwhich determines, among other things, how a user should receivecompliance information based on the preference information and forwardsthat information to the distribution management system 300 and theprint/fulfillment system 400. The fulfillment processor 208 alsoprocesses orders for the delivery of compliance information by thesystem. Any number of events may trigger the publication of complianceinformation to a user including, but not limited to, a particular timeevent (such as the beginning of the calendar year), transfer event (suchas a user obtaining or divesting a security), market event (such as astock split or corporate take over) or other event. With other forms ofcompliance information outside the area of securities, the particularcompliance rules may dictate when compliance information is to bepublished to a user. The fulfillment processor 208 may take compliancerules into account when determining how compliance information is to bepublished.

As shown in FIG. 3 the fulfillment processor 208 may receive fulfillmentorders from a brokerage 500 or from some other record-keeping system600. Communication between the document management system 200 and thebrokerage 500 or other entities is preferably done electronically (suchas through a network connection or through an Internet website) but maybe done over any medium including telephone, paper, wireless, or othercommunication method. Fulfillment orders may also come from othersources, such as directly from the user 1000 or from the compliancegoverning body (such as the SEC). Fulfillment orders are an example of arequest for the document management system 200 to publish complianceinformation. The record-keeping system 600 may be associated with abrokerage, may be internal to the document management system 200 or maybe associated with a different entity which supplies holding informationto the document management system 200. The fulfillment processor 208 mayreceive fulfillment orders individually or in batches. It may alsoreceive information regarding a user's account holdings or a user'stransaction information from the record-keeping system 600. Thisinformation may be used to ensure that the user is receiving the properportion of the compliance information and to send further complianceinformation if appropriate. The fulfillment processor 208 checks thefulfillment orders against its own internal rules, as well as thosestored in the preference database 206, and then forwards the checkedfulfillment orders to the distribution management system 300.Publication of compliance information may also be initiated by withoutbeing prompted. When deciding what compliance information to publish toa user, and when to publish it, the fulfillment processor 208 may alsotake into account rules governing the compliance information (forexample those rules set by the SEC which govern the exchange ofsecurities information) as well as information provided by therecord-keeping system 600, the brokerage 500, the user 1000, or otherinformation. While the fulfillment processor 208 preferably initiatespublication, the publication itself may be handled by a separate system,including the distribution management system 300 or theprint/fulfillment system 400.

In the embodiment shown in FIG. 1 and FIG. 4 , the distributionmanagement system 300, which handles electronic publication, and theprint/fulfillment system 400, which handles print publication, arepictured as separate systems from each other and from the documentmanagement system 200. They may be embodied as separate systems and evencontrolled by separate entities, but it should be understood, however,that they may be centralized and that publication may be handleddirectly by the document management system 200. Although the systems arepictured separately in the illustrated embodiment, the documentmanagement system 200, the distribution management system 300, and theprint/fulfillment system 400 may be located on similar machines and mayshare components. For example the document database 204, the preferencedatabase 206, the production database 302, and the print server 402 maybe the same machine or may be split between two or more machines. Forpurposes of illustration, however, the functions of these systems aredescribed separately, but it should be understood that there may beconsiderable overlap in their physical structure and in certaincircumstances structures of the systems may be interchanged.

Continuing with the description of the embodiment shown in FIG. 4 , oncethe fulfillment processor 208 determines to initiate publication itsends an order to either the distribution management system 300 or theprint/fulfillment system 400. The portion of the compliance informationto be published to the user 1000 depends on the preference instructions,delivery instructions and may also depend on the compliance rules.Whether the publication is electronic or in print also depends on thepreference information and delivery instructions. Publication may alsobe both electronic and by print. If the publication is to be electronic,the fulfillment order is sent to the distribution management system 300.

Electronic delivery is particularly helpful in the area of deliveringcompliance information because of the cost of distributing complianceinformation on paper. For certain users who have consented, and manyentities which must comply with the regulations, suppressing paperdelivery and opting for electronic delivery is a preferred option.

The distribution management system 300 makes use of a productiondatabase 302 which contains the compliance information stored on thedocument database 204. The production database 302 is preferablyregularly updated to ensure current information. That update may be donedaily by a standard Oracle database update. The production database 302provides the compliance information for the electronic delivery system304. Although not shown in this embodiment the production database mayalso provide compliance information for other components such as thee-mail engine 308.

Electronic publication may take many forms. Compliance information maybe sent by e-mail to a user 1000 and may either be contained in theemail or sent as an attachment, it may be stored on a server to whichthe user is given access directly or through a webpage, it may be sentto the user on an information storage device (such as a CD, disc, orcard) or may be sent directly to a user's computer over the Internet,through a different network, or over a wireless or telephone connection.If the compliance information is to be sent by e-mail, the complianceinformation is preferably sent from the fulfillment processor 208 to thee-mail engine 308 along with the delivery instructions. The complianceinformation may be formatted according to the preference information andother delivery instructions either by the fulfillment processor 208 orby the e-mail engine 308. The e-mail engine then publishes thecompliance information to the user 1000 through an e-mail message. Thecompliance information may be contained in or attached to the e-mailmessage, or the e-mail message may contain a link to the complianceinformation which the user 1000 may follow. The compliance informationmay be presented to the user as a collection of data which may beformatted by the user or may be sent as a discrete document which theuser may open (such as a spreadsheet file or .pdf or similar imagefile).

If a different form of electronic delivery is to be used the electronicdelivery system 304 may handle the publication, however the e-mailengine 308, the print/fulfillment system 400, or some other system (suchas a telephone message service) may be used to notify the user 1000 ofthe electronic publication of compliance information. This alternatenotification may depend upon the preference information and deliveryinstructions/information. One method of publication allows the user 1000to access the electronic delivery system 304 through an Internet websiteso that the user 1000 may obtain the appropriate compliance informationstored on the production database 302, and preferably presentedaccording to the preference information. The electronic delivery system304 may incorporate a web server for this purpose. The complianceinformation stored on the production database 302 may be storedaccording to preference information, but preferably is stored in adefault manner and the electronic delivery system 304 properly formatsthe compliance information according to the relevant preferenceinformation prior to viewing by the user 1000. Other electronicdelivery, such as on an information device, or though a separatenetwork, may be handled by the electronic delivery system 304 or othersystem. The distribution management system 300 may keep a record of eachpublication made. The document management system 200, and/or theprint/fulfillment system 400 may also keep a record of publicationhistory.

If publication of compliance information is to be by print thefulfillment processor 208 sends a print order to the print/fulfillmentsystem 400. As with the orders sent to the distribution managementsystem 300, orders to the print/fulfillment system 400 may be sent inbatches or individually. The orders tell the print/fulfillment system400 what compliance information to print and how it should be printedand sent according the preference information and delivery instructions.Orders are received by the job management system 404. The job managementsystem obtains the compliance information from the print server 402. Theprint server 402 contained in the document warehouse manager 104 isregularly updated and may be identical to (or even the same exactdatabase as) the production database 302 located within the distributionmanagement system 300. The print server 402 may store complianceinformation as both discrete documents and as data which may be easilymanipulated according to preference information to prepareindividualized documents. The print facility 406 creates a hard copy ofthe individualized documents. The print facility 406 may be automated,manual, or a combination of both. The job management system 404 thenprepares the printed compliance information for delivery to the user1000. Print delivery may be by mail, fax, express, bulk mail, or otherdelivery. In one embodiment, the print/fulfillment system 400 is able totake advantage of bulk mailing rates by grouping investor mailingstogether. For example, all investors scheduled to receive mailingscontaining 5 pages may be all set to print and be mailed at the sametime, thereby preserving the bulk mailing rates for those mailings. Inthis way costs may be reduced when distributing investor specificcompliance information.

In one embodiment dealing with securities information theprint/fulfillment system 400 may maintain an XML database of legallyfiled compliant envelopes for all variable contract prospectuses andsub-funds. This database may be located with the print server 402. Eachcompliant envelope may include, for a particular security, the AnnualReport, Semi-Annual Report, Prospectus, Statement of AdditionalInformation and all filed Supplements. This database may be sourceddirectly from EDGAR, where all mutual fund and insurance complaints mustfile these legal documents. Once obtained, the system converts the datato XML, HTML, and/or required print formats in a processing step similarto that described above for the loading processor 202. These formats maybe maintained in a compliant and programmatically updated warehousewhere thousands of filing changes occur each day, affecting up to onethird of the database. Preferably, all updates may be completed by thetime the next day's trading begins. This particular XML and databasemanipulation allows reduction of page counts for printed complianceinformation by eliminating unnecessary pages from the fulfillmentprocessor. A significant advantage of the XML format is the easytailoring for a participant, and resultant reduction in page count.

In prior art methods of distributing compliance information, investorswere provided with large packets of materials, many of which wereirrelevant to the investor. One result of providing information in thepresent manner is a reduction in costs associated with sorting andcoordinating the appropriate information for each individual. Oneembodiment of the system, provides paper information for investors thatis coordinated for each individual investor.

As illustrated in FIG. 5 , the prior art system of sending a fullproduct book of compliance information to a user is replaced by thepresent system of dividing the full product book into complianceinformation for several products. That specific compliance informationmay be arranged as individual documents by CUSIP number. They are thenmatched with individual investors' account holdings. Those productholders are then sent an appropriate book which combines only therelevant information for that particular user.

The method of print arrangement offered by the present system and methodis faster, more tailored to the user preference and less costly thansending hundreds of pages of information (much of it irrelevant to theuser) to each user every time new securities information is distributed.The present system and method allow real-time printing which mayincorporate branding and tailoring of the delivery to the appropriatebrokerage or end user.

The combination of preference based electronic and paper delivery allowsinformation distributors to dramatically reduce expenses from theircurrent inefficient warehouse practices. It also creates the ability toeasily incorporate users who decide to consent to electronic deliver.For print delivery, the system may be optimized so that job volume isdistributed and organized to minimize costs. Customized features andlogic may be used to minimize the number of total mailings. The systemalso allows the use fund profiles in place of prospectuses in thepre-sales distribution. The system may provide fund profiles tailored tothe wishes of the provider/brokerage and may deliver the confirmingprospectus upon the establishment of a subfund position. This maygenerate tremendous further savings and through the use of fundprofiles, deliver more relevant information to the investor. Once aposition is established, the prospectus may be sent out on aportfolio-specific basis.

This combined system of electronic delivery and specifically formattedpaper delivery provides compliance at significantly lower cost and muchhigher customer satisfaction than traditional warehouse and offsetprinting approaches.

Unless specifically stated herein, it should not be assumed that anydescribed particular aspect or element of the system is essential.Further, variations, modifications, and other implementations of what isdescribed herein will occur to those of ordinary skill in the artwithout departing from the spirit and the scope of the invention asclaimed. In addition, in view of the foregoing description, one ofordinary skill in the art will understand that equivalent structures maybe available to achieve the same results as those described above.Accordingly, the spirit and scope of the following claims should not belimited to the descriptions of the examples described herein.

What is claimed is:
 1. A system for distributing compliance informationto a user, the system comprising: a compliance information manager whichgathers compliance information from one or more sources; a preferencedatabase which stores data regarding delivery instructions for at leastone user; and a distribution manager which initiates publication of atleast a portion of the compliance information to the user based on thedata regarding delivery instructions.
 2. The system of claim 1 whereinthe publication comprises sending a physical copy of the portion of thecompliance information to the user.
 3. The system of claim 1 wherein thedistribution controller is located on the same machine as thedistribution manager.
 4. The system of claim 1 wherein the publicationinitiated by the distribution manager is executed by publishing theportion of the compliance information to the user in an electronicformat.
 5. The system of claim 1 wherein the distribution controllerdetermines how a user should receive compliance information furtherbased on compliance rules governing said compliance information
 6. Thesystem of claim 4 wherein the portion of the compliance information iscontained in the body of an e-mail message.
 7. The system of claim 4wherein the portion of the compliance information is sent as anattachment to an e-mail message.
 8. The system of claim 4 wherein theportion of the compliance information in electronic format is located onan information storage device sent to the user.
 9. The system of claim 4wherein the portion of the compliance information in electronic formatis stored on a server which is accessed by the user.
 10. The system ofclaim 9 wherein the server is located on the same machine as thedistribution manager.
 11. The system of claim 1 wherein the distributionmanager formats the portion of the compliance information prior topublication.
 12. The system of claim 1 wherein the data regardingdelivery instructions stored by the preference database includespreferences of the user.
 13. The system of claim 1 wherein the dataregarding delivery instructions stored by the preference databaseincludes preferences of a brokerage.
 14. The system of claim 1 whereinthe compliance information comprises securities information.
 15. Thesystem of claim 14 wherein the securities information comprises at leastone mutual fund prospectus.
 16. The system of claim 1 wherein at least aportion of the compliance information gathered by the complianceinformation manager is obtained from EDGAR.
 17. The system of claim 1wherein at least a portion of the compliance information gathered by thecompliance information manager is obtained from a brokerage.
 18. Thesystem of claim 1 wherein at least a portion of the complianceinformation gathered by the compliance information manager is obtainedfrom a publicly traded corporation.
 19. The system of claim 1 whereinthe distribution manager records the publication of at least a portionof the compliance information to the user.
 20. The system of claim 1wherein the distribution manager reports the publication of at least aportion of the compliance information to the user to a brokerage.